Privacy Policy

    Last updated: 10 October 2026

    Draft — pending lawyer review. This page may change before public launch.

    This Privacy Policy explains what personal data the Makan platform ("Platform", "we", "us") collects, why, who it is shared with, and the choices you have. It applies to Buyers, Organizers, Venue owners, and visitors to mak-an.io and our mobile applications. The Platform is operated by Makan, based in Iraq — see Terms & Conditions for the full entity details, which will be completed here once the company's incorporation is complete.

    This policy is written to a GDPR-style standard — covering what is collected, why, for how long, and what rights you have — because it also has to satisfy Iraq's E-Commerce Regulation No. 4 of 2025 (consent, data minimisation and breach-notification duties), the app stores, and buyers who reach us from the EU or UK. Iraq itself does not yet have a comprehensive data-protection law.

    1. What we collect

    CategoryExamples
    AccountEmail address, name, phone number, preferred language, password (hashed) or OAuth identity (Google, TikTok)
    VerificationOne-time codes sent by SMS/WhatsApp (via OTPIQ or Twilio Verify) for phone verification and login; two-factor authentication (TOTP) secrets and trusted-device tokens
    Orders & ticketsEvents and Venue bookings you make, ticket QR codes, order history, guest-checkout details (name, email, phone) if you check out without an account
    Payment referencesProvider transaction references and status from our payment gateways — we never see or store your full card number; card details are entered directly on the payment provider's hosted page
    Venue booking guestsName, phone and email of the person a booking is made for
    Device & risk signalsIP address (may be hashed), device identifiers, push-notification tokens, and basic signals used to slow down abuse at signup and checkout
    SupportMessages you send us through in-app chat or email, and their content
    DiagnosticsCrash reports and performance data from our error-monitoring tool; anonymous page-view and page-speed statistics for the website from Cloudflare Web Analytics (no cookies); on the mobile app, product-analytics events
    Organizer-specificIdentity documents and payout-account details submitted for organizer verification; organization details (name, contact, social links)
    Wallet passesIdentifiers used to add a ticket to Apple Wallet or Google Wallet

    2. Why we process it, and on what basis

    • To perform your order — create your account, process payment, issue your ticket, and let you attend an Event or use a Venue booking (contract).
    • To verify you — phone/email verification, fraud and abuse prevention (contract and legitimate interest).
    • To communicate with you — order confirmations, reminders, and support replies (contract); marketing updates only where you have opted in (consent, and you can opt out at any time).
    • To operate and improve the Platform — diagnostics, crash reporting, and product analytics (legitimate interest).
    • To verify Organizers — identity and payout-account checks before an organizer can receive payouts (legitimate interest and legal obligation, including anti-money-laundering expectations that flow down from our payment providers).
    • To comply with the law — tax, payment-provider and law-enforcement requests where applicable (legal obligation).

    3. Who we share it with

    RecipientWhat forNote
    SupabaseOur database and real-time featuresHosted in the EU
    VercelHosting and file storage (ticket PDFs, images, verification documents), until our move to Cloudflare is complete
    CloudflareDNS, content delivery and security for mak-an.io; hosting and file storage once our move from Vercel is complete; web analytics for the website (no cookies); and turning tickets, receipts, booking passes and finance documents into PDFs (Cloudflare Browser Run) — the document being printed, with the names and the ticket QR code on it, is sent to Cloudflare only for that, with caching switched offA global network, including data centers outside the EU
    PayTabs Iraq (Amwal)Card paymentsIraq
    ZainCashMobile-wallet payments and organizer payoutsIraq
    seats.ioSeat selection for seated EventsEU company
    SentryError tracking and diagnosticsSession-replay masking of sensitive fields is a work in progress
    IntercomIn-app support chat
    ResendTransactional email (sign-in codes, tickets, confirmations, receipts)Resend sends through Amazon Web Services; our own mail server is kept as a fallback route
    OTPIQ / Twilio VerifySMS and WhatsApp one-time codesTwilio may process your phone number outside Iraq
    Google, TikTokSign-in, and (Google) Wallet passes and MapsOnly if you use these sign-in options
    AppleWallet passesOnly if you add a ticket to Apple Wallet
    Cloudflare TurnstileBot detection at signup and checkout
    Event Organizers and Venue ownersYour name, contact details and ticket/booking status, for the specific Event or Venue you interact withThey act as an independent controller of this data under our Organizer Agreement
    Organizer-supplied advertising pixels (Meta, TikTok, Google Tag Manager, and similar)An Organizer's own marketing measurement on its own public Event/Venue pagesLoaded only on those public pages, and gated by a cookie-consent banner for EU/UK/EEA visitors

    We do not sell your personal data.

    4. International transfers

    Some of the processors above are located outside Iraq (the EU, the United States). Where that happens, we rely on the safeguards those providers make available (such as their own data-processing agreements) to protect your data in transit and at rest.

    5. How long we keep it

    • Payment, payout and KYC (organizer identity verification) records: at least 5 years, in line with anti-money-laundering expectations from our payment providers.
    • Account and order data: for as long as your account is active, and for a reasonable period after deletion to resolve any pending order, refund, or dispute.
    • Support messages and diagnostics: kept only as long as needed to resolve the matter or improve the Platform.

    6. Your rights

    Depending on where you are, you may have the right to access, correct, delete, or export your personal data, and to object to or restrict some processing. To exercise any of these rights, contact us using the details below. If you are in the EU or UK, you also have the right to lodge a complaint with your local data-protection authority.

    Account deletion: you can request deletion of your account from Settings or by contacting support. We are working to make sure a deleted account does not reappear if you sign in again through a linked provider (such as Google) — if that ever happens to you, please tell us.

    7. Children

    The Platform is not directed at children, and we do not knowingly collect personal data from anyone below the age required to enter into a contract in their jurisdiction.

    8. Security

    We take reasonable technical and organizational measures to protect your data, and we are actively working through a security review of our database access controls, identity-document storage, and account-deletion flow. This is a draft policy — we will not describe protections here as complete until that work is done.

    9. Marketing

    We only send marketing messages if you have opted in, and every marketing message includes a way to opt out.

    10. Cookies and tracking

    Visitors from the EU, UK or EEA see a cookie-consent banner before Intercom (chat), session replay, or an Organizer's own tracking pixels load; everyone else sees a simple notice with an opt-out. The banner explains what each of these tools does.

    The website statistics we collect ourselves (Cloudflare Web Analytics) use no cookies and no local storage, and Cloudflare states that it does not fingerprint visitors for them, so they run for every visitor and are not behind the banner.

    11. Changes to this policy

    We may update this policy as the Platform changes. When we do, we will update the "Last updated" date above.

    12. Contact us

    Questions about this policy, or a request relating to your data:


    Draft — pending lawyer review. This policy is grounded in how the Platform actually works today, but has not yet been reviewed by a licensed lawyer, and will be updated once it has.